Turnkey Processing, LLC., (“Turnkey”, “we” or “us”), the owner of this website and application, believes it is important to protect the privacy of our merchants, customers, and guests. We know that you care about how your personal information is collected, updated, used and shared. Furthermore, we want to help you make knowledgeable choices about the information you provide to us. The effective date of this policy is 8/28/18.
Turnkey is a financial technology and merchant services company which provides subscription based apps, and owns and operates various sites on the World Wide Web, including without limitation www.processwithturnkey.com (collectively, the “Services”).
Use of Personal Data
Do Not Track Disclosures
“Do Not Track” (DNT) is a preference that you may enable from your web browser to opt-out of online behavioral tracking. Our site and app does not follow DNT settings, and may collect personally identifiable information about you over time and across third party websites regardless of whether DNT is enabled or disabled in your browser. This Personal Data is used by us to provide targeted advertising to you for the products and services we sell. Please also be aware that some third party sites that we are linked to may keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you.
Passively Collected Information
When you interact with us through the website, we receive and store certain additional non- personally-identifiable information. For example, we automatically receive and record information on our server logs from your browser including your IP address, browser type and language, referring/exit pages and URLs, other browser history, platform type, number of clicks, landing pages, cookie information, the pages you requested and viewed, the amount of time spent on particular pages, and the date and time. Except as provided below under “Fraud Prevention,” we only use this data in aggregate form, that is, as a statistical measure, and not in a manner that would identify you personally. This type of aggregate data enables us to figure out how often users use parts of the website or Services so that we can make the website appealing to as many users as possible, and improve our Services. As part of this use of information, we may provide aggregate information to our partners about how our users, collectively, use the website. We share this type of statistical data so that our partners also understand how often people use their services and the website, so that they, too, may provide you with an optimal online experience. Again, Turnkey never discloses aggregate information to a partner in a manner that would identify you personally.
As part of our efforts to combat fraud, we may record your IP address when you use the Service, and confirm that the geographic location associated with your IP address matches the banking information you may provide us or a third party App Distributor. This process allows us to detect and prevent certain fraudulent transactions from being processed through the Service (for example, a payment request associated with a U.S. billing address, but a non-U.S. IP address, may be declined).
Aggregated Personal Data
In an ongoing effort to better understand our users, we may analyze the Personal Data that is provided to the website in aggregate form. This aggregate information does not identify you personally. We may share this aggregate data with our affiliates, agents and business partners. We may also disclose aggregated user statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.
In operating this website, we may use a technology called “cookies.” A cookie is a piece of information that the computer that hosts our website gives to your computer when you access a website. Our cookies help provide additional functionality to the website and help us analyze website usage more accurately. Company cookies do not collect Personal Data, and we do not combine the general information collected through cookies with other Personal Data to identify you personally.
Sharing Information: We won’t share your Personal Data with anyone except for the situations listed below or unless we specifically inform you and give you an opportunity to opt out of our sharing your Personal Data.
We may share your Personal Data with:
- Authorized service providers.
Our authorized service providers are companies that perform certain services on our behalf. These service providers may have access to your Personal Data to the extent necessary to perform their functions, but we do not allow them to share or use any of your Personal Data for any other purpose.
- Turnkey affiliates.
We may share information we collect, including Personal Data, with Turnkey-owned or affiliated businesses. Sharing information with our affiliates enables us to provide you with information about a variety of products and services that might interest you. All Turnkey companies comply with applicable privacy and security laws and, at a minimum, in any commercial email they send to you, will give you the opportunity to choose not to receive such email messages in the future.
- Protection of Turnkey and others.
We may release Personal Data when we believe in good faith that release is necessary to enforce or apply our Terms of Service and other agreements; or protect the rights, property, or safety of Company, our employees, our users, or others. This includes, without limitation, exchanging information with other companies and organizations for fraud monitoring, detection, and prevention.
- Other Situations.
We also may disclose your information:
- In response to a subpoena or similar investigative demand, a court order, or a request for cooperation from a law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases, we may raise or waive any legal objection or right available to us.
- In connection with a substantial corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.
Special Notice to International Visitors and Customers
Privacy laws differ across the globe. This website is hosted in the United States. If you are visiting from other regions with laws governing data collection and use that may differ from U.S. law, including those whose privacy laws may be stricter than U.S. law, please note that you are transferring your personal data to the United States to Turnkey. By providing your personal data, you consent to that transfer.
Storage and Period of Holding for Personal Information
Unless otherwise requested by you, Turnkey will continue to keep the Personal Data you or a third party App Distributor provided to us. If the reason for collecting your personal information no longer exists, we will delete the personal information at the appropriate required time if legally required by relevant applicable data protection law.
The website and Services are not intended for children under 13, and we do not knowingly collect information from children under the age of 13. Children aged 13 or older should not submit any personal information without the permission of their parents or guardians. By using the website and Services, you are representing that you are at least 18, or that you are at least 13 years old and have your parents’ or guardians’ permission to use website and our related services. In the event that we learn that we have collected personal information from a child under age 13 we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us at email@example.com.
No data transmissions over the Internet can be guaranteed to be 100% secure. Consequently, Turnkey cannot ensure or warrant the security of any information you or a third party App Distributor transmits to us and you assume all risks associated with the Personal Data supplied by you or the third party App Distributor. You should note that in using the website and Services, your information will travel through third party infrastructures which are not under our control. Once we receive a transmission of Personal Data, we make reasonable efforts to ensure security on our systems. We use secure server software (SSL) and firewalls to protect your information from unauthorized access, disclosure, alteration, or destruction. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered or destroyed by breach of such firewalls and secure server software.
If, at any time after registering, (i) you change your mind about receiving information from us or about the use of information volunteered by you, (ii) you need to update or modify any Personal Data, or (iii) you have any other questions or concerns regarding privacy at the website or associated with the Service, please send us a request specifying your new choice at firstname.lastname@example.org. We will make every effort to resolve your concerns.
What personal information do we collect from the people that visit our blog, website or app?
When ordering or registering on our site, as appropriate, you may be asked to enter your name, email address, mailing address, phone number, Business Information or other details to help you with your experience.
When do we collect information?
We collect information from you when you register on our site, subscribe to a newsletter, respond to a survey, fill out a form or enter information on our site.
How do we use your information?
We may use the information we collect from you when you register, make a purchase, sign up for our newsletter, respond to a survey or marketing communication, surf the website, or use certain other site features in the following ways:
• To personalize user’s experience and to allow us to deliver the type of content and product offerings in which you are most interested.
• To improve our website in order to better serve you.
• To allow us to better service you in responding to your customer service requests.
• To administer a contest, promotion, survey or other site feature.
• To send periodic emails regarding your order or other products and services.
How do we protect visitor information?
Our website is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our site as safe as possible.
We use regular Malware Scanning.
Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. In addition, all sensitive/credit information you supply is encrypted via Secure Socket Layer (SSL) technology.
We implement a variety of security measures when a user places an order enters, submits, or accesses their information to maintain the safety of your personal information.
All transactions are processed through a gateway provider and are not stored or processed on our servers.
Do we use ‘cookies’?
• Help remember and process the items in the shopping cart.
• Understand and save user’s preferences for future visits.
• Keep track of advertisements.
• Compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future. We may also use trusted third party services that track this information on our behalf.
You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser (like Internet Explorer) settings. Each browser is a little different, so look at your browser’s Help menu to learn the correct way to modify your cookies.
If you disable cookies off, some features will be disabled It won’t affect the users experience that make your site experience more efficient and some of our services will not function properly.
However, you can still place orders.
Third Party Disclosure
We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information unless we provide you with advance notice. This does not include website hosting partners and other parties who assist us in operating our website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or others’ rights, property, or safety.
However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.
Third party links
Occasionally, at our discretion, we may include or offer third party products or services on our website. These third party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.
Google’s advertising requirements can be summed up by Google’s Advertising Principles. They are put in place to provide a positive experience for users. https://support.google.com/adwordspolicy/answer/1316548?hl=en
We use Google AdSense Advertising on our website.
We have implemented the following:
• Remarketing with Google AdSense
• Google Display Network Impression Reporting
• Demographics and Interests Reporting
• DoubleClick Platform Integration
We along with third-party vendors, such as Google use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding user interactions with ad impressions, and other ad service functions as they relate to our website.
Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising initiative opt out page or permanently using the Google Analytics Opt Out Browser add on.
CT Online Privacy Protection Act
According to CTOPPA we agree to the following:
Users can visit our site anonymously
Users are able to change their personal information:
• By emailing us
• By calling us
• By logging in to their account
• By chatting with us or sending us a ticket
How does our site handle do not track signals?
We honor do not track signals and do not track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place.
Does our site allow third party behavioral tracking?
It’s also important to note that we allow third party behavioral tracking
COPPA (Children Online Privacy Protection Act)
When it comes to the collection of personal information from children under 13, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, the nation’s consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online.
We do not specifically market to children under 13.
Fair Information Practices
The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.
In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur:
We will notify the users via email
• Within 7 business days
We will notify the users via in site notification
• Within 7 business days
We also agree to the individual redress principle, which requires that individuals have a right to pursue legally enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or a government agency to investigate and/or prosecute non-compliance by data processors.
CAN SPAM Act
The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.
We collect your email address in order to:
• Send information, respond to inquiries, and/or other requests or questions.
• Process orders and to send information and updates pertaining to orders
• We may also send you additional information related to your product and/or service.
• Market to our mailing list or continue to send emails to our clients after the original transaction has occurred
To be in accordance with CANSPAM we agree to the following:
• NOT use false, or misleading subjects or email addresses
• Identify the message as an advertisement in some reasonable way
• Include the physical address of our business or site headquarters
• Honor opt-out/unsubscribe requests quickly
• Allow users to unsubscribe by using the link at the bottom of each email
If at any time you would like to unsubscribe from receiving future emails, you can
• Follow the instructions at the bottom of each email.
and we will promptly remove you from ALL correspondence.
816 Broad Street Suite 10, Meriden, CT USA 06450